London Calling

At a time when housing delivery has fallen well below both identified need and previous London Plan targets, the Mayor has rightly placed growth, housing and delivery at the centre of the new strategy. However, while the Government's standard method identifies a requirement for around 880,000 homes over a ten-year period, the Draft London Plan proposes a target of 558,000 homes. This shortfall raises the question of whether the draft Plan is sufficiently ambitious, a matter that is likely to dominate the consultation process.

Although not a new concept, the emphasis on making the best use of land, optimising site capacity and delivering housing through a more flexible policy framework is encouraging. While policy safeguards remain important, there is growing recognition across the sector that viability challenges, construction costs and regulatory burdens have contributed to London's disappointing housing delivery performance. A London Plan that prioritises implementation and delivery, rather than adding further policy requirements, is likely to be welcomed by stakeholders.

Another significant shift is the evolving approach to Metropolitan Open Land (MOL) and the Green Belt. Historically, the London Plan has afforded MOL protection equivalent to that of the Green Belt. The new Plan seeks to differentiate between MOL and the Green Belt, suggesting there will not be complete alignment with national policy on grey belt land. However, the Mayor's willingness to undertake a strategic review of Green Belt and MOL land acknowledges a reality: brownfield land alone is unlikely to deliver the scale of housing required. Importantly, this is not a blanket removal of protections. Instead, it reflects a more nuanced approach, focusing on lower-quality land, sustainable locations and opportunities to secure environmental improvements alongside development, with golf courses specifically referenced. The housing figures include 56,000 homes on Green Belt land, and the draft Plan promotes dense residential development, with factors such as proximity to railway stations influencing the scale of development.

Another notable change is the removal of the dedicated small sites housing targets and associated policy framework that formed a key component of the 2021 London Plan.

The previous Plan placed significant reliance on small sites to contribute towards housing delivery across London. This change suggests a move away from prescriptive small site targets, with a greater focus on overall delivery, land optimisation and the identification of larger strategic opportunities. The challenge, however, will be ensuring that the removal of specific small site requirements does not inadvertently reduce opportunities for incremental development and intensification, both of which will continue to play an important role in meeting London's housing needs and providing a variety of housing types. This is particularly important at a time when small housebuilders need support. Again, this is likely to be a key point of debate during the consultation process.

As the consultation progresses, there will be an important opportunity for boroughs, landowners, developers and communities to help shape the final document. We are actively reviewing the Draft London Plan and would be pleased to assist clients in preparing consultation representations, assessing the implications for development sites and promoting land through the emerging plan-making process.